Explanatory Notes

Introduction

Part 5: Group relief

Chapter 6: Equity holders and profits or assets available for distribution

Section 171: Shares or securities with temporary rights

688.This section and section 172 require an alternative calculation if an equity holder’s rights (either to profits or to assets in a winding up) are capable of changing. Both sections are based on paragraph 5 of Schedule 18 to ICTA.

689.Subsection (1) sets the scope of the section. If it applies, the consequences are set out in section 172. The calculation is made at the “relevant time” (see section 169(2)).